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Standard Interpretations
01/25/2006 - Requirements for carrying and stacking lumber with nails.
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• Standard Number: 1926.95(a); 1926.250(b)
OSHA requirements are set by statute, standards and regulations. Our interpretation letters explain these requirements and how they apply to particular circumstances, but they cannot create additional employer obligations. This letter constitutes OSHA's interpretation of the requirements discussed. Note that our enforcement guidance may be affected by changes to OSHA rules. Also, from time to time we update our guidance in response to new information. To keep apprised of such developments, you can consult OSHA's website at http://www.osha.gov.

January 25, 2006

Luigi Piccioli, Jr.
[Via e-mail]

Re: Requirements for carrying and stacking lumber with nails.

Dear Mr. Piccioli:

This is in response to your e-correspondence sent May 8, 2005, to the Occupational Safety and Health Administration (OSHA). You ask about applicable OSHA requirements for carrying and stacking lumber with nails. We apologize for the delay in responding.

We have paraphrased your questions as follows:

Question (1): Does OSHA require that nails be removed from or bent down on lumber that will be carried by employees?

Answer: There is no construction standard that specifically addresses the hazards from protruding nails on lumber that is to be carried by employees. However, 29 CFR 1926.95(a) provides that:
[p]rotective equipment, including personal protective equipment for eyes, face, head, and the extremities, protective clothing, respiratory devices, and protective shields and barriers, shall be provided, used, and maintained in a sanitary and reliable condition wherever it is necessary by reason of hazards of processes or environment, chemical hazards, radiological hazards, or mechanical irritants encountered in a manner capable of causing injury or impairment in the function of any part of the body through absorption, inhalation, or physical contact.
In addition, section 5(a)(1) (the General Duty Clause) of the Occupational Safety and Health Act of 1970 (OSH Act) states:
Each employer shall furnish to each of his employees employment and a place of employment which are free from recognized hazards that are causing or likely to cause death or serious physical harm to his employees.
Nails protruding from lumber can cause impalement and cutting hazards. Where those hazards are present, §1926.95(a) would require the employer to provide and require the use of some type of protective equipment by its employees that are exposed to that hazard. We recognize that it would be difficult to protect workers tasked with handling the lumber from this hazard with personal protective equipment such as gloves, since most gloves would not be effective in protecting against this hazard. However, another means of protection would be to remove the nails or bend them down. That would also meet the employer's obligations in this regard under the General Duty Clause.

Question (2): When stacking lumber, does OSHA require the lumber to be free of nails?

Answer: Yes, §1926.250(b) states:
*****
(8) Lumber:
(i) Used lumber shall have all nails withdrawn before stacking.
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Therefore, before stacking lumber all nails must be removed.

If you need any further information, please contact us by facsimile at: U.S. Department of Labor - OSHA, Directorate of Construction, Office of Construction Standards and Guidance 202-693-1689. You can also contact us by mail at the above office, Room N3468, 200 Constitution Avenue, NW, Washington, DC 20210; although, there will be a delay in our receiving correspondence by mail.

Sincerely,



Russell B. Swanson, Director
Directorate of Construction
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